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City of Santa Ana <br />Limited English Proficiency (LEP) Plan <br />November 2017 <br />into 80 different languages. All of the City's public counters are staffed with bilingual speakers for <br />the two most common languages requested in the City of Santa Ana, Spanish and Vietnamese. <br />Costs for marketing materials and translation of documents for outreach are minimal and have not <br />been quantified. <br />S. Summary <br />Based on the four -factor analysis, the City of Santa Ana has identified the language needs and <br />services required to provide meaningful access to information for the LEP residents of Santa Ana. <br />This LEP Plan will be reviewed on an annual basis and incorporate LEP information that further <br />identify additional language needs for the top languages identified. <br />VI. PLANNING— DEVELOPING A LANGUAGE ASSISTANCE PROGRAM (LAP) <br />A. Identification of LEP Persons <br />City staff will use the following methods to identify LEP persons: <br />• Examine records to see if requests for language assistance have been ,received in the past, <br />either at meetings or from referrals to determine whether language assistance might be needed for <br />future events or literature. <br />• Provide language identification forms which invite LEP persons to identify their language needs <br />to our staff members. Records will be maintained for a 3 -year period. <br />Safe Harbor Provision. DOT has adopted DOJ's Safe Harbor Provision, which outlines circumstances <br />that can provide a "safer harbor' for recipients regarding translation of written materials for LEP <br />populations. The Safe Harbor Provision stipulates that, if a recipient provides written translation of <br />vital documents for each eligible LEP language group that constitutes five percent (5%) or 1,000 <br />persons, whichever is less, of the total population of persons eligible to be served or likely to <br />be affected or encountered, then such action will be considered strong evidence of compliance <br />with the recipient's written translation obligations. Translation of noh-vital documents, if needed, <br />can be provided orally. If there are fewer than 50 persons in a language group that reaches the five <br />percent (5%) trigger, the recipient is not required to translate vital written materials but should <br />provide written notice in the primary language of the LEP language group of the right to receive <br />competent oral interpretation of those written materials, free of cost. <br />These safe harbor provisions apply to the translation of written documents only. They do not affect <br />the requirement to provide meaningful access to the LEP individuals though competent oral <br />interpreters where oral language services are needed and are reasonable. A recipient may determine, <br />based on the Four Factor Analysis, that even though a language group meets the threshold specified by <br />the Safe Harbor Provision, written translation may not be an effective means to provide language <br />assistance measures. For example, a recipient may determine that a large number of persons in that <br />language group have low literacy skills in their native language and therefore require oral <br />interpretation. In such cases, a background documentation regarding the determination shall be <br />55C-23 <br />17 <br />